Chapter 6 of 812% of exam
Business Operations, Internal Controls and AML
How a licensed firm must run itself: internal controls and senior-management responsibility, anti-money-laundering duties, and the protection of clients' personal data.
Controls, AML and data
The Management, Supervision and Internal Control Guidelines and GP9 place ultimate responsibility for controls and compliance on senior management. Under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO) and the SFC's AML/CFT Guideline, firms must carry out customer due diligence, monitor on a risk-based approach, and report suspicious transactions to the Joint Financial Intelligence Unit (JFIU) without tipping off the client. Personal data is governed by the Personal Data (Privacy) Ordinance.